The Environmental Protection Agency hands out some of the most significant fines among all government regulators. In the first few months of 2021, the EPA fined companies over $1 million due to various Resource Conservation and Recovery Act violations.
These charges ranged from improper disposal of hazardous waste to something we often see as a hazardous waste disposal company: improper labeling. Companies that fail to label their waste properly put themselves at risk during DEP inspections.
With over two decades of experience handling hazardous waste, HWH Environmental understands and values the importance of labeling. To help you and your business avoid costly fines and/or shutdowns, we put together this quick guide with all the information you’ll need to know when labeling your hazardous waste.
What is Hazardous Waste Labeling?
Hazardous waste labeling is used to identify and classify potentially dangerous waste materials to ensure proper handling, transport, and disposal. These stickers convey the type of hazardous waste inside the containers.
Hazardous waste materials are classified based on their potential to cause harm to human health or the environment. The labeling system is designed to facilitate easy identification and handling of these materials by individuals and organizations.
In addition, the labeling system may also include color coding or other visual indicators that help to identify the type of hazard present quickly.
While the EPA enforces many hazardous waste labeling requirements, it is also essential to consider state-specific requirements. Since each state has its procedures, it’s best to check with them first if you have any questions.
What Happens if You Don’t Label Hazardous Waste Correctly?
The most common consequence of failing to label hazardous waste is EPA fines. Within the past year, there have been hundreds of thousands of dollars in fines issued to hazardous waste creators as a result of improper (or nonexistent) labeling.
EHS Daily Advisor reported in 2021 about a medical center fined for a failure to mark or label containers of hazardous waste. In addition, they failed to keep multiple containers in the 90-day central accumulation areas closed nor did they indicate the hazards of the content and the date of accumulation. Their total fine was $105,500.
Also in 2021, a chemical plant in Oregon was fined over $300,000 due to storing hazardous waste longer than allowed and failing to properly label their hazardous waste containers.
Companies across the country are discovering the consequences of failing to properly label their hazardous waste.
Common Hazardous Waste Labeling Mistakes to Avoid
Proper labeling of hazardous waste is crucial for safety and compliance. Even minor errors can lead to significant fines and environmental hazards. Here are some common mistakes to watch out for:
1. Incomplete or Missing Labels
Every hazardous waste container must be clearly labeled with:
- The words “Hazardous Waste”
- A description of the waste’s hazards (e.g., ignitable, corrosive, toxic)
- The accumulation start date
Failing to include any of these can result in non-compliance.
2. Illegible or Damaged Labels
Labels must remain legible and intact throughout the waste’s storage period. Exposure to chemicals or environmental conditions can cause labels to degrade, rendering them unreadable.
Regularly inspect and replace labels as needed to ensure clarity.
3. Incorrect Hazard Identification
Misidentifying the waste’s hazard class can lead to improper handling and increased risk.
Ensure accurate classification by referencing Material Safety Data Sheets (MSDS) and consulting with environmental professionals when necessary.
Importance of Hazardous Waste Labeling
Hazardous waste labeling is more than just a checkbox for inspectors to mark off during their facility visits. These procedures protect employees and the environment from improper handling and accidental spills.
Properly labeling hazardous waste materials ensures that individuals handling or transporting these materials are aware of the potential hazards and can take the necessary precautions to protect themselves and others.
This includes using personal protective equipment, such as gloves or respirators, and following specific handling and storage guidelines to prevent accidental spills or releases.
Another benefit of hazardous waste labeling is on the off-chance that somehow a container of materials goes missing; the bright, easy-to-understand stickers allow people to identify dangerous waste and call for assistance immediately.
Hazardous Waste Labeling Requirements
The RCRA requires all hazardous waste labels to include the following pieces of information:
- The words hazardous waste
- Potential hazard of the contents (e.g., ignitable, toxic, reactive, corrosive)
- The date on which accumulation began
Sometimes, these are 4×4 diamond-shaped stickers with colorful images that draw attention to the hazardous materials in these containers; at other times, they are square-shaped with more detailed written information on them.
It is essential to inspect these containers and labels periodically to ensure that the information remains legible, includes all necessary details, and is visible.
This information is necessary for storage only as there are different requirements from the Department of Transportation.
For guidance about the Department of Transportation Hazardous Waste Labels, visit their hazardous materials labeling, markings, and placards guide.
Need Help Labeling Your Hazardous Waste? Contact HWH Environmental Today.
The last thing your company wants is to incur unnecessary fines due to improper hazardous waste labeling. EPA expectations are straightforward, enabling you to stay focused on running the business rather than worrying about regulations.
As a hazardous waste hauling company with over 25 years of experience in the field, we’ve seen our fair share of mislabeled containers.
If you have any questions about proper hazardous waste labeling or are in need of our hazardous waste disposal services, contact our experts today.
